IR 05000298/1989016

Insp Rept 50-298/89-16 on 890501-05.Violations Noted.No Deviations Noted.Major Areas Inspected:Selected Areas of Radiation Protection Program as Set Forth in Core Insp Program,As Related to Outage Activities

ML20244C949
Person / Time
Site:	Cooper
Issue date:	06/02/1989
From:	Baer R, Ricketson L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20244C941	List: ML20244C938 ML20244C942 ML20244C949
References
50-298-89-16, NUDOCS 8906150219
Download: ML20244C949 (8)

Text

- _ _ _ _ _ _ _ - - _ _ -_ __

-

,

APPENDIX B U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-298/89-16 Operating License: DPR-46 Docket: 50-298 Licensee: Nebraska Public Power District (NPPD)

P.O. Box 499 Columbus, NE 68602-0499 Facility Name: Cooper Nuclear Station (CNS)

Inspection At: CNS, Brownsville, Nebraska Inspection Conducted: May 1-5, 1989 Inspector: h fA ,9,u n b n og:y s , m ,- 4 ~L -Pf L.' T. R! cketsorp,~ PkE. , Radiation Speciali st Date Facilit- eyRapologfM1' Protection Section

'

l

Approved: 6- SE9 Rf E. Baer, Chief, Facili..es Radiological Date l Protection Section Inspection Summary Inspection Conducted May 1-5, 1989 (Report 50-298/89-16)

Areas Inspected: Routine, unannounced inspection of selected areas in the radiation protection program as set forth in the core inspection program (83750), as they related to outage activitie Results: Planning and preparation for outage activities supported ALARA principle Staffing of Health Physics (HP) appeared adequate to handle the demands brought about by outage work. The HP technicians were judged to be technically qualified. The radioactive material transportation program was adequate. Two examples of one apparent violation were identified in the area of radioactive material and contamination controls (see paragraph 8). No deviations were identifie ~

8906150219 DR 890605 ADDCK 0500029s PNU

- _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ -

- . _ - _ _ - _ _ _ _ _ _.

,

.

.

.

DETAILS l Persons Contacted NPPD

• H. Horn, Nuclear Operations Division Manager

• J. V. Sayer, Radiological Manager

• T. J. Chard, HP Supervisor R. L. Beilke, Radiological Support Supervisor

• D. R. Robinson, Quality' Assurance Suptrvisor G. R. Smith, Licensing Supervisor

• L. E. Bray, Regulatory Compliance Specialist B. L. Hall, Health Physicist T. E. Carson, ALARA Coordinator J. H. Kuttler, HP Specialist D. P. Oshlo, Lead HP Technician J. P. Morris, Chemistry Technician NRC, Reaion IV

• A. Pick, Resident Inspector

• M. McNeill, Reactor Inspector In addition to the above, the NRC inspector contacted other licensee and contractor personnel during the intra etio * Denotes those present at the exit meeting on May 5, 1989. Inspector Observations The following observations were discussed with the licensee during the exit meeting. Inspector observations are not violations, deviations, or open items, but were identified for the licensee's consideration for possible program improvement. Observations have no specific regulatory requirement ALARA packages documenting prejob planning and other efforts taken by the licensee to reduce radiation exposure did not contain attendance lists for prejob briefings given by HP or ALARA personne Increased surveillance of contract workers in less frequented controlled areas by the HP staff would have improved contamination control .

. _ _ - - _ . . _ - _ _ - - - _--

_ _ _ _ _ _ _ _ _ - _ - _ - _ _ - _ __

- - - -

.

,

. Followup on Previous Inspection Findings (Closed) Open Item (298/8910-01) - Hot Particle Controls Around Laundr Monitor. This item was discussed in NRC Inspection Report 50-298/89-10 and involved the lack of controls around the laundry monitor and the handling of potentially contaminated protective clothing. After the previous inspection, the licensee's radiological protection staff evaluated the operation and instituted contamination controls. The NRC inspector verified that a rope barrier surrounded the laundry monitor and -

the area was labeled as contaminated. Individuals working inside the barrier wore gloves, booties, and lab coats. Laundry to be monitored was treated as contaminated until monitored and found to be clean.

s Individuals were required to clear personnel contamination monitors upon completion of work in the are . Planning, Preparation, and ALARA In order to review the licensee's planning and preparation, the NRC inspector attended daily meetings of department supervisors in which the progress of outage activities was discussed, along with upcoming projects. The NRC inspector noted that the discussions were open and participants seemed cooperative. The NRC inspector also attended meetings >

of the ALARA committee and of the HPs at shift change. All involved a good exchange of information; such as job progress, problem areas, possible alternate work methods, radiation levels, and special precaution The NRC inspector verified that the ALARA coordinator received a listing of work to be performed and that an ALARA review was performed when deemed '

appropriate. The NRC inspector reviewed selected ALARA packages and found them to be comprehensive, except lists of attendance for prejob briefings ,

were not included in the package l The NRC inspector determined that individuals involved in the ALARA reviews had adequate knowledge of plant systems and maintenance procedures. The NRC inspector noted, however, that the former ALARA'

coordinator, still working half time reviewing ALARA packages', had attended a formal course in ALARA training, while the new ALARA

oordinator had not. The individual's supervisor stated to the NRC inspector that the training was planned, but had not yet been schedule The licensee's representatives stated that, in way of preparation, a mockup was used for training purposes in preparation for work on the control rod drives. In addition, a film of the drywell was used to help

,

i orient individuals with that area before they performed work _there,_and a i vendor representative conducted training in the procedure for the removal of the source range monito _ _ _ _ _ _ . _

y

'

.,

' ^'

• ,

4-

.

, n q

The licensee established a' goal:of 185.5 man-rem.for.the outage, which i began April 8, 1989, and.a' goal of 275 man-rem for.the. year. The total; !

exposure through week 17 was' approximately 101 man-rems for the outage

~

(based on pocket dosimeter data thusfar) and 133 man-rem'for'the year, No violations'or deviations were. identifie b Staffing and Qualification l The NRC inspector reviewed the staffing plan for the outage and!noted that; the licensee had recruited 20 senior contract technicians and 8 junior- ,

contract technicians for additional HP supportLduringithe outage. ?Before-hiring the technicians, a background check was madeto determine as.much as possible about 'the' work history and qualifications ofe the individual All' senior technicians were qualified in accordance with recommendations of Industry Standard ANSI N18.1-1971. Technicians were given the~ site-

~

specific HP procedures for review and were required to' demonstrate-a ..

i practical knowledge of them. The NRC inspector reviewed selected _ record documenting this process. During the course of.the inspection,'the NRC_ a inspector interviewed approximately eight. technicians at random and found-them to be sufficiently qualified. The work force of house technicians remained fairly stable over the last 16 months with a turnover. rate'o about 10 percen ~

The NRC inspector also reviewed station radiation protection procedures identified in the attachment to this repor No violations or deviations were identifie . Radiation Exposure Controls )1 The licensee's external and internal controis were examined for agreement with 10 CFR Parts 20.101, 20.102, 20.103, 20.104, 20.105,~' 20.202, 20.203, 20.205, 20,206, and~ recommendations of'RG 8.1 As determined during the previous inspection, the license'e 'uses thermoluminescent dosimeters from a vendor. Representatives of the'

licensee stated that, should it;be necessary, the' vendor could process:the badges and provide exposure data in 3-4 days. The licensees'

representatives stated that there would be jobs requiring individuals t i; wear multiple. badges and that'there were an adequate number of dosimetry i devices. The NRC inspector confirmed that there had been' no instanceLo an individual receiving more than the allowable ~1imits of exposur :

l

'

The NRC inspector confirmed that air sampling was performed in work areas l and that' calibrated continuous air monitors were in use. The licensee's representatives stated that, based on whole body counting, there has been no ingestion of radioactive materia '

No violations or deviationr, were identifie .i i

i

!

_ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ . _ _ _ _ _ -

____

_,

.- !- V

'

':

,

.,

. ,

,

i

.

'

i i

Posting, Labeling, and Worker Controls

.!

The licensee's program of! posting, labeling, and' worker controls were examined for agreement with 10 CFR Parts 19.12, 20.203, 20.205, and-20.20 j]

.:

The NRC inspector observed that posting andlabeling were appropriate and adequate. HP coverage at main stepoff pad was judged, by the NRC inspector, to be adequate but, as noted in paragraph 7, lessl often :

used stepoff pads needed.to be checked more ofte . Control of Radioactive Material and Contamination,' Surveys, and Monitoring Thelicensee'sprogramofcontrolofIradioactive'materialand ..

contamination, surveys, and monitoring was' examined for. agreement with:

Technical Specification (TS) 6.3.4.and 10 CFR Parts 20.201, 20.301, and 20.40 i TS 6.3.4 requires that procedures shall be mainta'ined and made availabl to all station personnel . . . and shall.be. consistent with the-requirements of 10 CFR 20. 10 CFR 20.201(b) requires that-the licenseeL make such radiation surveys as may be necessary to evaluate the extent of radiation hazards that may be present. HP Procedure 9.2.3,Section VIII.B.I, requires that equipment and tools used in a controlled

.

I area be surveyed by instrument or smear prior to removal from the are While observing in-service inspection activities, the NRC inspector'

observed an individual working in Residual Heat Removal (RHR) Heat '!

Exchanger Room A, a contaminated area, hand a' piece of electrical conduit  ?

!

'

to another individual standing outside the area boundary without first having the conduit checked for-contamination by HP. The individual accepting the conduit stated that he had just handed it to the person inside the contaminated area, who tried to put in place, found it to be j too long, and returned it for trimming. . He' stated that he accepted the : q item with his bare hand and immediately put it in a: plastic bag.and that-he had forgotten that all items removed from the area should have been surveyed first. HP personnel directed the individual to a hand and foo monitor. No contamination was found. The conduit was not checked at the~ +

time and therefore no information was available about its actual contamination leve The NRC inspector also observed, in RHR Heat Exchanger Room B, that hangers made from steel I-beams were laying across the stepoff pad and partially'

-

] ;

outside a controlled area. These hangers were removed from the walls in the contaminated part of the room and were later found to have approximately 300 disintegrations per minute of radioactive coritaminatio .

The failure to perform smear surveys on both the conduit and the hanger to -

determine contamination levels are two examples of an apparent' violation l of TS 6. J

!

l

_ _ - _ _ - _ _ _ _ - _ - _ _ ___ _ .\

_ _ _

- - _ _ _ - _ - - _

,. ., .

-

,

!. Records of surveys were examined during the previous -inspection and the; survey program was found to be comprehensive. Selected examples of surveys, involving work performed during the outage, were examined and-they too were found to be adequate. An adequate supply of calibrated

. survey instruments was availabl ~The NRC inspector observed that both hand and foot monitors and personnel contamination monitors were available in sufficient' numbers and were used appropriately by individuals leaving the contaminated areas. The NRC inspector determined that the number (92)- of personnel contamination incidents for the outage thusfar was approximately double the number for the similar time period of the last outage. The licensee's representatives stated they felt, based on the type and location of the contamination found on individuals, the reason for the. increase was poor undressing techniques used by employees of.the primary contractor and not-the lack of hot particle control Licensee management addressed this point on April 22, 1989, in a memo to the contractor, emphasizing the need  !

for following the proper undressing. procedure. The licensee's representatives further stated that remedial training would be used if the rate of personnel contamination did not significantly decreas No deviations were ident1fie . Transportation The licensee's transportation program was inspected to' determine )

compliance with 49 CFR 170-179 and 10 CFR 7 The licensee made 32 shipments in 1988 and 12 thusfar in 1989. Shipments were made using steel liners., drums, and casks. Preparation and documentation of shipments is the responsibility of the radiological support portion of the radiological departmen i The NRC inspector examined a shipment consistinc of compacted (except for one container) dry waste which was being prepared for shipment to- '

Richland, Washington. The NRC' inspector noted that the strong, tight-containers (crates) appeared to be adequately braced and blocked to prevent shifting during transportation. The NRC inspecto'r randomly verified the licensee's surveys of the surfaces of the trailer containing the radioactive waste. No radiation levels above 15 mR/h on contact were detected. The shipment was labeled as low specific activity. The licensee supplied calculations supporting the classificatio The NRC inspector reviewed documentation of various previous shipments of i radioactive materials and concluded that it was adequate for those examples. The NRC inspector verified that a certificate of compliance was on file for the cask used and that the licensee was listed as a use No violations or deviations were identifie :

_ _ _ _ _ - _ _ _ _ - _

. - - - - - _ _ _ _ -

. . .

.

n

.

7 Exit Meeting The NRC inspector met with the resident inspector and the licensee's representatives, denoted in Section 1, and summarized the. scope and the-findings of the inspection and the inspector's' observations as presented in this repor i i

i

-- .._.-______________]

m , -

,

- >

,

s

, 9

,. -

.j

-

a- , , _

=- -i

,

t* .

. > u .-

,

- - >

, -j

>

.,

. .

'

,

,

d ATTACHMENT-PROCEDURES REVIEWED Ittle Bevi si en Date 9.1.1.2: CNS Hot Particle _. Program L '

'

9.1. Speci al Work Permit: . 17 ~2-23-89 1 9. Protective Clothing (Anti-C) L8; 9-24-87::

9. Radiation and Contamination' Survey Frequency 15= 2-20-8 . Radiation Survey

'

L 1 . Contamination Surveys L7' 12-08-88- ,

9. Surveying Materialifor. Release Offsite 1~ 7--01-87-9. Constant Air Monitors (CAM) 6' 2-23-89 9. Radioactive Sources Control.and 6 6-30-88 Accountability 9.S. Radioactive Waste Shipment for Burial .6 8-11-88-9.5. Radioactive Material Shipment 4l -8-11-88'

,.

f -

s

____._________._m___ _ _ . _ . - _ - --